At 05:30 20 January 2005, Pete Brown wrote:

(yada yada yada)

In the old days, prior to the rewrite the SSA had an

exemption, much like the data plate exemption, that
allowed
towing by private pilots for compensation by SSA chartered

clubs. (Up to that point, compensation, as defined
by the
FAA, included the logging of time even if the pilot
was not
paid.)

I don't believe there ever was an 'exemption' per se,
but an understanding by John Lynch and his predecessors
in the General/Commercial division at FAA. IIRC, logging
flight time surfaced as a 'compensation' issue in the
context of drug testing rules from which soaring operators
were excluded in 1988/89.

I believe 61.113(g) was intended to codify the intent
that tow pilots - particularly those active in club
operations - need not be commercial rated if 'compensation'
is limited to the logging of flight time.

Lynch (who has not retired, but was on a leave of absence
for military duty last year) phrased it in the October
2004 edition of the Part 61 FAQ:

'Q&A 619 § 61.113(g); Yes. . . A private pilot who
meets the requirements of § 61.69 of this part may
act as pilot in command of an aircraft towing a glider
. . And yes, a private pilot who meets the requirements
of §61.69 of this part may log pilot in command flight
time while towing a glider. That is what was intended
when paragraph § 61.113(g) was drafted into Part 61.


Later in the same document, Lynch explains with respect
to § 61.113(g): 'The answer is no, a private pilot
may not receive compensation for towing a glider.


The intent, and the wording of the § 61.113(g), was
to permit a private pilot who meets the requirements
of § 61.69 of this part to “. . . act as pilot in command
of an aircraft towing a glider” for the purpose of
logging pilot in command (PIC) time. The new rule
was never intended to conflict with the FAA’s long
standing legal interpretations and policies on compensation
for private pilots. And the wording of the § 61.113(g)
only addresses the issue that permits a private pilot
to “. . . act as pilot in command of an aircraft towing
a glider” for the purpose of permitting a private pilot
to log pilot in command time. As you recall, the wording
of the old § 61.69 permitted a private pilot to act
as a PIC but was moot on logging the time. The § 61.113(g)
was issued to correct it.

However, we agree the wording of the § 61.113(a) may
be confusing. In the next go-around on correcting
some of the wording mistakes, we have recorded it as
a needed correction to conform the intent and the wording
of § 61.113(g).'


Judy



The rewrite in 1997(?) of Part 61 was supposed to
eliminate
the need for the towing exemption. All they did was
further
confuse the issue.

Pete


--

Peter D. Brown
http://home.gci.net/~pdb/
http://groups.yahoo.com/group/akmtnsoaring/